ORAUT-OTIB-0052 

Parameters to Consider When 

Processing Claims for 

Construction Trade Workers

Report from the Subcommittee for Procedure Reviews (SCPR)

Presented to the

Advisory Board on Radiation and Worker Health

Redondo Beach, California

December 13–14, 2017

1
ORAUT-OTIB-0052, “Parameters to Consider When Processing 

Claims for Construction Trade Workers”

• ORAUT-OTIB-0052 provides guidance for performing dose 

reconstructions for unmonitored construction trade workers (CTWs)

• Revision 00, August 31, 2006

 SC&A review of Revision 00, June 6, 2006

– Identified 16 findings

– 5 closed during June 24, 2008, meeting

• Revision 01, February 11, 2011

 SC&A review of Revision 01 (focusing on remaining findings), July 2011

• Revision 02, July 24, 2014

2
Finding 1: OTIB-0052 does not address differences in doses received 

by different construction occupations.

• It was determined that this finding issue was addressed by Finding 16, 

so it was combined with that finding.

 The SCPR transferred Finding 16 (and by extension Finding 1) to 

OTIB-0020.

 On November 14, 2011, NIOSH issued OTIB-0020, Revision 03, 

with the requested change to address the OTIB-0052 findings. 

• Resolution: In April 2012, the SCPR was satisfied with the change and 

closed this finding along with Finding 16.

3
Finding 2: The dose databases used are lacking significant data for 

the early operational years.

• NIOSH concurs with SC&A’s postulation that a reason for relatively 

low CTW exposure during the early years of site operations is that the 

CTWs would more likely be involved with initial facility construction

rather than retrofits. This would involve less radiation dose potential. 

Any deficiency in data during early operational years would apply to 

all monitored workers, not just CTWs, and would therefore tend to be 

an unbiased source of uncertainty.

• Resolution: The SCPR was satisfied with this response and closed the 

finding in June 2008.

4
Finding 3: The dose databases do not always identify who were 

CTWs, and for CTWs, what were their occupations.

• NIOSH response: 

 The dose databases constitute the best available source of 

information for a large population (more than 179,000 bioassay 

values and 216,000 external dose data values for CTWs were 

included in the analysis). 

 The criteria used to identify CTWs were either set at the time the 

record was created by site personnel or were identified in the 

OTIB in a description of the database query.

• Resolution: The SCPR was satisfied with this response and closed the 

finding in June 2008.

5
Finding 4: NIOSH did not make modifications to the internal dose 

calculation methodology, as they indicated to the Center to Protect 

Workers’ Rights (CPWR) that they would.

• NIOSH response:

 The CPWR agreed-upon modifications (i.e., increase the geometric 

standard deviation) resulted in “implausibly large values.” 

 A better course of action was available based on actual CTW bioassay 

data rather than assumed intakes based on air concentration. 

 The resulting method is believed to provide a more site-specific-based 

approach to dose reconstruction that is favorable to the claimant.

• Resolution: Based on NIOSH’s response and comments during the 

August 2007 meeting, the SCPR closed the finding in June 2008.

6
Finding 5: Plutonium and/or uranium were used to compare 

internal CTW to all monitored workers (AMW) doses. What about 

other radionuclides? 

• NIOSH responded that the vast majority of bioassay data in the DOE complex are for plutonium and uranium. Data on other radionuclides are 

limited in timeframe and number of results. Consequently, meaningful comparisons between the groups for less prominent radionuclides were 

not judged to be feasible.

• SC&A was not satisfied with NIOSH’s response and asked a series of follow- up questions.

• NIOSH proposed changes to OTIB-0052 to satisfy SC&A’s concerns.

• NIOSH issued Revision 01 in February 2011, and SC&A reviewed the 

document.

• Resolution: Based on the change made by NIOSH in Revision 01 regarding 

this issue and SC&A’s concurrence, the Subcommittee closed this issue in 

July 2011.

7
Finding 6: OTIB-0052 does not address how to determine CTW 

doses at sites that do not have a coworker model.

• NIOSH response:

 For sites lacking coworker studies, the dose for unmonitored CTWs 

is reconstructed in the same way as for other unmonitored 

workers with a potential for exposure or intakes (See Section 8.1 in 

OTIB-0052). 

 The site technical basis document provides direction on how to 

assign external and internal doses, and then the appropriate 

adjustment factor defined in OTIB-0052 is applied.

• Resolution: SC&A and the SCPR were satisfied with this response, and 

the SCPR closed the finding in June 2008.

8
Finding 7: Does not address how to determine neutron CTW doses.

• NIOSH response: 

 External doses were not intentionally differentiated according to 

gamma or neutron doses, so no inherent bias in reconstruction of 

neutron dose is likely. 

 Note that neutron dose is normally associated with access to special 

nuclear materials, which requires a security clearance or security 

escort. 

 Workers with security clearances were known and likely to be 

monitored. Consequently, it is reasonable to assume that the neutron 

dose would be higher in the group of all monitored workers than in the 

somewhat more transient CTW group.

• Resolution: SC&A and the SCPR were satisfied with this response, and 

the SCPR closed the finding in June 2008.

9
Finding 8: All Savannah River Site (SRS) external doses are from the 

HPAREH. NIOSH needs to evaluate other dose databases, e.g., 

Fayerweather, SRS-ABST.

• NIOSH response: 

 No additional value is gained in this case by expending resources 

to study the contents of other, less complete, databases. 

 There is no reason to believe that including the Fayerweather 

database in the ORAUT-OTIB-0052 analysis would change the 

results of that study for the SRS or for the ratio of 1.4 to be applied 

to external coworker models. 

• Resolution: SC&A and the SCPR were satisfied with this response, and 

the SCPR closed the finding in August 2008.

10
Finding 9: Evaluation is based on DOE annual exposure report. 

NIOSH needs to address the Master Update Dump (MUD) dose 

database for Idaho National Laboratory (INL).

• NIOSH responded that the MUD database covers the time period prior to 1986. The data in the Annual Reports is equivalent (because the Annual 

Report was created from the MUD data) for the overlapping time periods.

• SC&A disagreed with NIOSH’s response and presented evidence showing 

that the data are not equivalent.

• NIOSH presented its proposed changes to ORAUT-OTIB-0052 to address 

this issue. 

• NIOSH issued Revision 01 in February 2011, and SC&A reviewed the 

document.

• Resolution: Based on the change made by NIOSH in Revision 01 regarding this issue and SC&A’s concurrence, the Subcommittee closed this issue in 

July 2011.

11
Finding 10: For post-1974, the ratio of penetrating doses experienced 

by CTWs to other workers in OTIB-0052 does not agree with the INL 

epidemiologic study (NIOSH 2005), which indicates a correction factor 

closer to 2, and perhaps greater for some job types.

• NIOSH responded that the unmonitored CTW at INL would not have 

worked in a radiation area, so assigning the CTW a dose equal to 1.4 times the non-CTW dose would be very claimant favorable.

• SC&A disagreed and requested additional information.

• NIOSH presented its proposed changes to OTIB-0052 to address this issue. 

• NIOSH issued Revision 01 in February 2011, and SC&A reviewed the 

document.

 NIOSH added a new paragraph to Section 5.13 that explains that the NIOSH 2005 data were not used, because the service workers are grouped with 

CTWs, a practice that is inconsistent with the approach taken in OTIB-0052. 

• Resolution: Based on the change made by NIOSH in Revision 01 regarding 

this issue and SC&A’s concurrence, the Subcommittee closed this issue in 

July 2011.

12
Finding 11: Claimant favorability of OTIB-0052 approach for INL 

early period internal dose (to 1965) cannot be determined.

• NIOSH explained that the reason pipefitters at SRS received higher 

doses during the 1960s was the major modifications taking place in 

the F and H Canyons. Since these are classified areas, all workers 

would have been monitored, and any unmonitored CTWs (the 

subjects of OTIB-0052) would have received lower exposures.

• SC&A presented evidence that led them to believe that the INL pre- 1965 internal dose is not well known or documented. 

• Resolution: Based on the change made by NIOSH in Revision 01 

regarding this issue and SC&A’s concurrence, the Subcommittee closed 

this finding in July 2011.

13
Finding 12: The REX dose database was not used. NIOSH needs to 

compare results based on the REX database to those given in 

OTIB-0052.

• NIOSH explained that electronic access to the REX database was not available 

when the report was drafted. However, the data in REMS were derived from the 

data in REX and are judged to adequately represent the ratio of CTW and AMW 

doses.

• SC&A explained that Section 6 of OTIB-0052 needs to be revised to indicate that 

the Hanford analysis was based on REX data provided by the site expert and not 

based on the references provided in the present version of Section 6.

• NIOSH presented its proposed changes to OTIB-0052 to address this issue. 

• NIOSH issued Revision 01 in February 2011, and SC&A reviewed the document.

• Resolution: Based on the change made by NIOSH in Revision 01 regarding this 

issue and SC&A’s concurrence, the Subcommittee closed this finding in November 

2014.

14
Finding 13: The CTW doses need to be compared consistently to 

either AMW or non-CTWs. Currently, different sections perform 

different comparisons.

• NIOSH response: 

 Because CTW doses are similar to or higher than AMW doses, the calculated ratios, 

which are used to form an adjustment factor, tend to be similar or higher when non- CTW is used in the denominator instead of AMW. 

 The baseline method is to use AMW in the denominator, but the ratio would tend to 

be more favorable to the CTW population when non-CTW data are used in the 

denominator. 

 Regardless of comparison method, the outcome would be favorable to CTWs 

because the correction is typically applied to doses in a site-specific coworker model 

based on data for all monitored workers.

• SC&A examined the SRS HPAREH penetrating data from 1953 to 1999 and 

determined NIOSH’s response was correct and recommended closure. 

• Resolution: The SCPR agreed with SC&A’s recommendation and closed the finding 

in April 2012.

15
Finding 14: The handling of “missing dose” needs to be consistent. 

Currently, some sections include “missing dose” while others do 

not.

• NIOSH explained that regardless of how missed dose was treated, the sitespecific comparison between CTWs and AMW was fair because missed 

dose was handled consistently for both groups within each site.

• SC&A requested additional discussion on how the adjustment factors were 

selected and why dose ratios calculated using different methodologies can 

be compared.

• After extensive discussions, it was determined that both Average Adjusted 

CTW to AMW ratios are less than the recommended correction factor. In 

addition, NIOSH added appropriate wording to Section 4 of the OTIB.

• Resolution: In July 2012, the SCPR closed the finding.

16
Finding 15: No instructions are given for what to do if high or low 

cumulative exposures are suspected.

• NIOSH explained that the normal assessment methods defined in 

OTIB-0020 for these types of exposures apply. The method in OTIB- 0052 does not change when either low or high cumulative exposures 

are suspected.

• The SCPR agreed that OTIB-0020 was a better document to address 

this issue and transferred the finding to OTIB-0020.

• On November 14, 2011, NIOSH issued OTIB-0020, Revision 03, with 

the requested change to address the OTIB-0052 findings.

• Resolution: In April 2012, the SCPR was satisfied that the change to 

OTIB-0020 addressed the OTIB-0052 concern and closed the finding.

17
Finding 16: Some construction occupations (e.g., pipefitters) receive 

exposures larger than the average CTW exposure. The average 

member of such groups may consistently receive external exposures 

above the 95th percentile, but possibly not by much. Occupational 

details in the data are not plentiful enough to define percentile value.

• SC&A recommended that this issue be transferred to OTIB-0020, with a 

statement alerting the dose reconstructor that certain construction trades 

(e.g., pipefitters) may have received higher exposures than the CTW as a 

whole, and therefore, additional conservatism should be included in the 

dose reconstruction when the claimant belongs to one of these trades.

• The SCPR agreed that OTIB-0020 was a better document to address this 

issue and transferred the finding.

• On November 14, 2011, NIOSH issued OTIB-0020, Revision 03, with the 

requested change to address the OTIB-0052 findings.

• Resolution: In April 2012, the SCPR was satisfied that the change to 

OTIB-0020 addressed the OTIB-0052 concern and closed the finding.

18
Questions?

19